Overview
Iris Bennett has more than two decades of experience representing companies and individuals in the defense and resolution of criminal and civil investigations by the U.S. DOJ and other U.S. agencies. She has represented clients in all phases of U.S. government investigations, settlement, and post-settlement compliance before the Department of Justice Criminal and Civil Divisions and the Securities and Exchange Commission, and with respect to voluntary and mandatory disclosures before these agencies as well as the U.S. Department of Defense Office of the Inspector General.
Iris has led hundreds of cross-border and domestic internal investigations on behalf of companies and Boards of Directors into issues of legal or policy compliance. Her global cross-border experience has included numerous matters in which Iris's fluency in Spanish and knowledge of Portuguese has facilitated execution of all key aspects in those languages. Her international experience includes serving as US investigation counsel to the Independent Committee chaired by appointed by the Board of Directors of Vale S.A., with a mandate to investigate the causes and responsibilities for the 2019 rupture of the Córrego do Feijão tailings dam in Brumadinho, Brazil.
Ranked in Chambers USA and Chambers Global for FCPA, clients note Iris is "an outstanding lawyer, gives excellent advice and has a very good practical understanding of business reality," describing her as "exactly the person you want next to you in an emergency." She has also been named to the "GIR Top FCPA Practitioners" and "GIR Women in Investigations" lists by Global Investigations Review.
Iris maintains an active ethics and compliance counseling practice focused on providing strategic and actionable advice. She has advised Fortune 100 corporate clients and many other companies on their anti-corruption compliance programs, corporate compliance reviews and risk assessments, targeted compliance consultations to resolve ad hoc issues, and transactional and third-party due diligence.
Iris served as the Independent Compliance Monitor for SNC-Lavalin, Inc., with a mandate to review and evaluate that company's global anti-corruption compliance program on behalf of the World Bank in a matter that involved the longest-ever World Bank debarment and monitorship sanction. Under her oversight, SNC-Lavalin successfully completed its sanctions obligations to develop a robust anti-corruption compliance program and was able to obtain an early release from what had been a 10-year debarment. Iris also served as U.S. counsel to the Independent Compliance Monitor appointed by the Department of Justice and the U.S. Securities and Exchange Commission for a Swedish-listed, multinational networking and telecommunications company.
Before entering private practice, Iris served as a trial attorney with the District of Columbia Federal Defender, representing criminal defendants in federal court.
- District of Columbia
- California
- Virginia
- Supreme Court of the United States
- US District Court, District of Columbia
- US Court of Appeals, Seventh Circuit
- Hon. David S. Tatel, US Court of Appeals, District of Columbia
- Hon. Robert W. Sweet, US District Court for the Southern District of New York
- J.D., New York University School of Law, 1999, magna cum laude
- A.B., Harvard College, 1989, summa cum laude
Areas of Work
Speaking Engagements
- "Corporate Enforcement Priorities for Your Neighbor to the North: the Implications of Recent Developments in U.S. Anti-Corruption, Sanctions, and National Security Policy for Companies in Mexico," Private Program, Steptoe and Sanchez-DeVanny (Monterrey), May 16, 2024
- "Relevant Aspects for Non-Trial Resolutions in the Negotiation Phase," Non-Trial Resolutions as a Tool to Combat Corruption in Latin America Conference, May 7, 2024
- "US Government Enforcement Priorities and Policy Developments," International Chamber of Commerce México, February 28, 2024
- Co-Panelist, "Are exclusions the new normal?", IBA Annual Conference Paris 2023, Paris, France, November 1, 2023
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Co-Panelist, "ESG: Evolving Regulation and New Enforcement", 19th Annual International Bar Association (IBA) Anti-Corruption Conference, Paris, June 14, 2023
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Speaker, "POCA and FCPA – Pitfalls to Avoid," Steptoe, Control Risks, JSA Advocates and Solicitors, Gurugram, India, April 11, 2023
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"Shadow Investigations What are the Limited to be Respected and the Best Practices," LEC 9th International Compliance Congress, São Paulo, Brazil, September 22, 2022
- "Updates from Brazilian Enforcement Agencies Part II – CGU Experience on Evaluating and Monitoring Anticorruption Compliance Programs," ACI's 11th Summit on Anti-Corruption Brazil, São Paulo, Brazil, May 26, 2022
News & Publications
Investigations & Enforcement Blog
UK, France and Switzerland Announce New Task Force To Tackle International Corruption Alliance
March 31, 2025
Publications
Perspective on the Executive Order on FCPA Enforcement
The Compliance and Ethics Blog
February 17, 2025
Publications
The Legal and Compliance Implications of the Supreme Court's Snyder Decision
The Anti-Corruption Report
September 13, 2024
By: Brigida Benitez, Iris E. Bennett, Patrick F. Linehan, Nicholas P. Silverman
Press Releases
Global Investigations Review Names Steptoe a Top 30 International Investigations Firm
November 21, 2023
International Compliance Blog
DOJ Announces "Safe Harbor" Policy for Mergers & Acquisitions
October 24, 2023
By: Andrew C. Adams, Iris E. Bennett, Lee Berger, Brian J. Fleming, Patrick F. Linehan, David M. Stetson, Brittney Denley, Quentin Johnson
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2022 Year in Review
February 24, 2023
By: Iris E. Bennett
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jingchun (Cherry) Huang, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)
Events
Webinars
Quarterly Investigations & Enforcement Update
April 24, 2025
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Michelle Kallen, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Policy Perspectives Roundtable - Examining the Trump Administration's FCPA Position
February 20, 2025
Speakers: Jason Abel, Iris E. Bennett, Sandra Hanna, Zoe Osborne, Claire Rajan
Webinars
Quarterly Investigations & Enforcement Update
October 30, 2024
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Amba M. Datta, Sandra Hanna, Ryan Hayden, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
July 31, 2024
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
May 1, 2024
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
January 25, 2024
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
October 19, 2023
Speakers: Andrew C. Adams, Jason Abel, Iris E. Bennett, Christopher R. Conte, Patrick F. Linehan, John J. Kavanagh, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
January 26, 2023
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Coy Garrison, Patrick F. Linehan, Zoe Osborne, Wendy Wysong
Noteworthy
- Global Investigations Review: The Top FCPA Practitioners (2021)
- Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists from Around the World" (2021)
- Chambers Global, International Trade: FCPA, US (2021-2024)
- Chambers USA, International Trade: FCPA, Nationwide (2021-2024)
Professional Affiliations
- Co-Chair, Foreign Training Committee, National Association of Criminal Defense Lawyers
- Co-Chair, White Collar Committee, National Association of Criminal Defense Lawyers
- Advisory Board, The Champion journal, National Association of Criminal Defense Lawyers
- Co-Chair, Newsletter Committee, Women’s White Collar Defense Association